SMILE Privacy Policy

Last updated: February 9, 2026

1. Overview

SMILE (Stanford Mobile Inquiry-based Learning Environment) is an educational platform designed to support inquiry-based learning, assessment, and collaboration in institutional educational settings. This Privacy Policy explains what data SMILE collects, how it is used, and how it is protected.

SMILE is committed to student privacy, data minimization, and education-only use of personal data.

This policy complies with international privacy standards including GDPR, COPPA, FERPA, and Korean child privacy laws (Personal Information Protection Act).

2. Data We Collect

SMILE collects only the minimal data necessary to operate educational learning activities.

Account Information

  • User ID (automatically generated)
  • Name (first and last)
  • Email address (required for account recovery)
  • Date of birth (optional, for age verification when required)
  • Role (student, teacher, admin)

Learning Activity Data

  • Questions submitted
  • Responses and comments
  • AI evaluation results (quality scores and feedback)
  • Activity participation timestamps
  • Group memberships
  • Assessment scores and progress

Guardian Consent Records (for users under 14)

  • Guardian name and email
  • Relationship type (parent, legal guardian, teacher)
  • Consent status and timestamp
  • Consent method (email link, teacher code, admin verification)

What SMILE Does NOT Collect:

  • Government ID numbers or social security numbers
  • Biometric data
  • Precise geolocation data
  • Behavioral tracking across websites
  • Financial information
  • Health or medical information

3. Purpose of Data Collection

Personal data is used strictly for educational purposes:

  • Account Management: Create and maintain user accounts
  • Learning Activities: Deliver questions, assessments, and collaborative activities
  • AI Evaluation: Provide automated quality feedback on student questions and responses
  • Progress Tracking: Enable teachers and students to monitor learning progress
  • Group Collaboration: Facilitate communication within learning groups
  • Guardian Protection: Verify parental consent for users under 14
  • Security: Maintain system security and prevent unauthorized access

SMILE does NOT:

  • Sell personal data to third parties
  • Use data for advertising or marketing
  • Profile users for non-educational purposes
  • Share data with unauthorized parties

4. Data Retention Period

SMILE retains personal data only as long as necessary to support educational use:

  • Active users: Data retained while user account is active
  • Inactive users: Data retained up to 24 months after last activity
  • Account deletion request: Data deleted within 30 days with 30-day grace period
  • Guardian consent withdrawal: Student account disabled, data handled per retention policy
  • Institutional request: Bulk deletion supported for schools
  • Research data: Only anonymized and aggregated data retained indefinitely

5. Children Under 14 Protection (한국 아동 개인정보 보호)

SMILE allows students under 14 years old with mandatory guardian consent.

Guardian Consent Requirements

For students under 14 (under 13 in some jurisdictions), guardian consent is REQUIRED before account activation:

  • Method 1: Email verification link sent to guardian email
  • Method 2: Teacher-generated consent code (for institutional use)
  • Method 3: Admin manual verification (for special cases)
  • Method 4: Institutional authority consent (school-wide approval)

Account Restrictions Without Consent

Students under 14 WITHOUT guardian consent have restricted access:

  • Cannot create or join groups
  • Cannot submit questions or responses
  • Cannot access collaborative features
  • Account marked as "Pending Guardian Consent"

Guardian Rights

Guardians of students under 14 have the right to:

  • View: Access their child's learning data
  • Correct: Request correction of inaccurate data
  • Delete: Request account and data deletion
  • Withdraw Consent: Revoke consent at any time (account will be disabled)
  • Export: Download complete data export

Minimal Data for Minors

SMILE collects minimal necessary data from users under 14:

  • Name (for educational interaction)
  • Email (for account recovery only)
  • Learning activity data (questions, responses, scores)
  • NOT collected: Location, biometrics, behavioral tracking

6. Third-Party Data Processors & AI Vendors

SMILE uses trusted service providers to operate the platform. All providers process data solely to support SMILE educational services.

Infrastructure Providers

  • Google Cloud Platform (GCP)
    Purpose: Secure hosting, database infrastructure, SSL certificates
    Data Processed: All user data stored on GCP servers
    Location: United States, compliant with international data protection standards
  • Google OAuth
    Purpose: User authentication only
    Data Processed: Name, email, Google user ID
    Scope: openid, email, profile (no access to Drive, Gmail, Calendar, etc.)

AI Evaluation Providers

  • OpenAI (GPT-4)
    Purpose: AI evaluation of student questions and responses for educational quality
    Data Sent: Question text, Bloom's taxonomy level, keywords (NO personally identifiable information)
    Data NOT Sent: Student names, email addresses, or other personal data
    OpenAI Policy: Data NOT used to train models (Enterprise Privacy)
  • Anthropic Claude
    Purpose: AI evaluation of student questions and responses for educational quality
    Data Sent: Question text, Bloom's taxonomy level, keywords (NO personally identifiable information)
    Data NOT Sent: Student names, email addresses, or other personal data
    Anthropic Policy: Data NOT used to train models (Anthropic Privacy)

Communication Providers

  • SendGrid (Email Service)
    Purpose: Send account verification, password reset, and guardian consent emails
    Data Processed: Email addresses, email content
    GDPR Compliant: Yes

Data Protection Safeguards

  • All providers bound by data processing agreements
  • Data encrypted in transit (TLS/SSL) and at rest
  • No provider has permission to use data for their own purposes
  • Regular security audits and compliance reviews
  • AI providers do NOT receive student names or personal identifiers

7. User Rights

All users (and guardians of users under 14) have the following rights:

Right to Access

View all personal data SMILE has collected about you.

Available at: My Data Page

Right to Correction

Correct inaccurate or incomplete personal data.

Available at: Account Settings or contact CPO

Right to Deletion

Request complete deletion of your account and all associated data.

Available at: My Data Page → Delete Account
Process: 30-day grace period, then permanent deletion

Right to Data Portability

Export all your data in machine-readable JSON format.

Available at: My Data Page → Export Data

Right to Stop Processing

Request that SMILE stop processing your personal data (account will be disabled).

Contact: CPO (see Section 12)

Response Time: All requests processed within 30 days.

8. Security Measures

SMILE protects personal data using industry-standard security practices:

Technical Safeguards

  • Encryption: HTTPS/TLS 1.3 for all connections
  • Database: PostgreSQL with encrypted storage on GCP
  • Passwords: Hashed using bcrypt (never stored in plain text)
  • Session Security: Secure cookies, automatic timeout
  • API Security: Token-based authentication, rate limiting

Administrative Safeguards

  • Access Control: Role-based permissions (student, teacher, admin)
  • Admin Access: Limited to authorized personnel only
  • Audit Logs: All admin actions logged with timestamps
  • Monitoring: 24/7 system monitoring for unauthorized access

Physical Safeguards

  • Cloud Infrastructure: GCP data centers with physical security
  • Redundancy: Automatic backups, disaster recovery plans
  • Compliance: SOC 2, ISO 27001 certified infrastructure

9. Google Authentication

Users may sign in using Google OAuth. When this method is used, SMILE receives only:

  • Name
  • Email address
  • Google unique user identifier

Scope Limitations: SMILE requests only basic OAuth scopes (openid, email, profile). We do NOT request or access:

  • Google Drive
  • Gmail
  • Contacts
  • Calendar
  • Any other Google user data

Authentication tokens are used solely for identity verification.

10. Data Ownership

  • Students: Retain ownership of their submitted content (questions, responses, work)
  • Educational Institutions: May access learning data for legitimate academic purposes
  • SMILE: Acts solely as a data processor, not data owner
  • Research: Only anonymized and aggregated data used, no personal identifiers

11. International Data Processing

SMILE operates globally and may process personal data in secure infrastructure operated by trusted service providers (primarily Google Cloud Platform in the United States).

Data Protection Safeguards:

  • All data transfers comply with GDPR and international privacy standards
  • Standard contractual clauses with all international processors
  • Encryption in transit and at rest
  • Regular compliance audits

12. Chief Privacy Officer (CPO) Contact

For privacy questions, data access requests, corrections, deletions, or concerns:

Chief Privacy Officer (CPO)
Seeds of Empowerment

Email: info@seedsofempowerment.org

Phone (International): +1 650-280-7769

Response Time: We aim to respond to all privacy requests within 30 days.